Indoor Air Quality in Commercial and Institutional Buildings (OSHA 3430)

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   Indoor Air Quality in Commercial and Institutional Buildings

   • OSHA 3430-04 2011
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   Occupational Safety and Health Act of 1970

   • “To assure safe and healthful working conditions for working men and women; by authorizing enforcement of the standards developed under the Act; by assisting and encouraging the States in their efforts to assure safe and healthful working conditions; by providing for research, information, education, and training in the field of occupational safety and health.”
   • This publication provides a general overview of a particular standards-related topic. This publication does not alter or determine compliance responsibilities which are set forth in OSHA standards, and the Occupational Safety and Health Act of 1970. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts.
   • Material contained in this publication is in the public domain and may be reproduced, fully…
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   Indoor Air Quality in Commercial and Institutional Buildings

   • Occupational Safety and Health Administration
   • U.S. Department of Labor
   • OSHA 3430-04
   • 2011
   • The guidance is advisory in nature and informational in content. It is not a standard or regulation, and it neither creates new legal obligations nor alters existing obligations created by OSHA standards or the Occupational Safety and Health Act. Pursuant to the OSH Act, employers must comply with safety and health standards and regulations issued and enforced by either OSHA or by an OSHAapproved State Plan. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their workers with a workplace free from recognized hazards likely to cause death or serious physical harm.
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   Contents

   • Introduction
   • Background
   • Benefits of Mitigation of IAQ Problems
   • Health Effects
   • Sources of Indoor Air Pollutants
   • Common Pollutant Categories
   • Prevention or Control IAQ Problems
   • IAQ Management Approach
   • Identification and Assessment
   • Control Methods
   • Seeking Professional Assistance
   • Applicable Standards and Regulations
   • OSHA Standards
   • Standard Interpretations
   • State Programs
   • National Consensus Standards
   • OSHA Assistance, Services and Programs
   • Appendix A: Common Indoor Air
   • Contaminants
   • Appendix B: Steps to Improve
   • Indoor Air Quality
   • Appendix C: HVAC System
   • Maintenance Checklist
   • Appendix D: Investigating IAQ
   • Problems and Complaints
   • Appendix E: Selected Resources
   • Hazard Recognition
   • Evaluation and Control
   • Appendix F: OSHA-Sponsored
   • Environmental Tobacco Smoke
   • Workshops
   • Workshops I - III
   • References
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   Introduction Background

   • Indoor air quality (IAQ) is a major concern to businesses, schools, building managers, tenants, and workers because it can impact the health, comfort, well-being, and productivity of the building occupants. OSHA recognizes that poor IAQ can be hazardous to workers’ health and that it is in the best interest of everyone that building owners, managers, and employers take a proactive approach to address IAQ concerns.
   • IAQ has been identified by the EPA as one of the top five most urgent environmental risks to public health (2). The Centers for Disease Control and Prevention (CDC) estimates that the majority of Americans spend approximately 90 percent of their time indoors (3). On average, office workers spend approximately 40 hours a week in office buildings. These workers also study, eat, drink, and, in certain work settings, sleep in enclosed environments where make-up air (i.e., fresh air added to recirculated air) may be compromised. …
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   • Building Council (USGBC), among others, has demonstrated that IAQ issues can be readily and practically addressed when building systems are retrofitted for energy efficiency. (http://www.usgbc.org/
   • DisplayPage.aspx?CMSPageID=221#v2008)
   • Benefits of Mitigation of IAQ Problems
   • Good IAQ in buildings is an important component of a healthy indoor environment. It contributes to a favorable and productive environment for building occupants, giving them a sense of comfort, health, and well-being. Significant increases in worker productivity have also been demonstrated when the air quality was adequate (6). Research has also shown that workers in buildings with adequate air quality have reduced rates of symptoms related to poor air quality (7).
   • Health Effects
   • Symptoms related to poor IAQ are varied depending on the type of contaminant. They can easily be mistaken for symptoms of other illnesses such as allergies, stress, colds, and influenza. …
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   Sources of Indoor Air Pollutants

   • The relative importance of any single source depends on how much of a given pollutant it emits, how hazardous those emissions are, occupant proximity to the emission source, and the ability of the ventilation system (i.e., general or local) to remove the contaminant. In some cases, factors such as the age and maintenance history of the source are significant.
   • Sources of indoor air pollution may include:
   • Building Site or Location: The location of a building can have implications for indoor pollutants. Highways or busy thoroughfares may be sources of particulates and other pollutants in nearby buildings. Buildings sited on land where there was prior industrial use or where there is a high water table may result in leaching of water or chemical pollutants into the building.
   • Building Design: Design and construction flaws may contribute to indoor air pollution. Poor foundations, roofs, facades, and window and door openings may allow pollutant or water intrusion. …
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   Common Pollutant Categories

   • Prevention and Control of IAQ Problems
   • Although there are numerous indoor air pollutants that can be spread through a building, they typically fall into three basic categories: biological, chemical, and particle (1).
   • IAQ Management Approach
   • Biological
   • Excessive concentrations of bacteria, viruses, fungi, dust mites, animal dander, and pollen may result from inadequate maintenance and housekeeping, water spills, inadequate humidity control, condensation, or water intrusion through leaks in the building envelope or flooding.
   • Chemical
   • Sources of chemical pollutants (gases and vapors) include emissions from products used in the building (e.g., office equipment; furniture, wall and floor coverings; pesticides; and cleaning and consumer products), accidental spills of chemicals, products used during construction activities such as adhesives and paints, and gases such as carbon monoxide, formaldehyde, and nitrogen dioxide, which are products of combustion.
   • Particle (Non-biological)
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   • Lastly, following up with affected personnel will serve to validate the effectiveness of the mitigation activities. For more information about the IAQ management approach, refer to OSHA’s Safety and Health Topics Page on Injury and Illness Prevention Programs. (http://www.osha.gov/dsg/topics/safetyhealth/the effectiveness of ventilation (5, 26), and excessive population density (e.g., overcrowding).
   • Ensure that good housekeeping practices are being applied.
   • Ensure that routine preventive maintenance and upkeep of buildings is being performed. A preventive maintenance program provides the care to all building systems and components that keeps them operating at peak performance according to manufacturer’s specifications, and also allows for early detection of problems
   • (1, 18).
   • Ensure that scheduled renovations are isolated from the building’s general dilution ventilation system when occupants are in the building.
   • index.html).
   • Identification and Assessment
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    • to provide thermal comfort, distributes adequate amounts of outdoor air to meet the ventilation needs of building occupants, and also dilutes and removes odors and other contaminants. Testing and rebalancing of HVAC systems are essential when partitions are moved in buildings. Appendix C contains an HVAC System Maintenance Checklist that can be used to assist in routine maintenance of the HVAC system. For certain situations, such as painting and carpet cleaning, temporarily increasing ventilation can help dilute the concentration of vapors in the air.
    • c. Air cleaning
    • Air cleaning primarily involves the removal of particles from the air as the air passes through the HVAC equipment. Most HVAC system filtration is provided to keep dirt off of coil surfaces to promote heat transfer efficiency. Most smudging observed around air supply diffusers in a ceiling result from entrainment (trapping) of dirt particles in the space that accumulate there because of poor housekeeping.
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    Applicable Standards and Regulations

    • OSHA does not have a general IAQ standard, but does provide guidelines addressing the most common workplace complaints about IAQ, which are typically related to temperature, humidity, lack of outside air ventilation, or smoking. OSHA standards address potential hazardous conditions leading to serious physical harm or death. Such standards may include those for specific air contaminants, ventilation systems, or the General Duty Clause of the Occupational Safety and Health Act of 1970 (OSH Act). This section highlights OSHA standards, standards interpretations (official OSHA letters of interpretation of its standards), and national consensus standards related to IAQ.
    • OSHA Standards
    • All OSHA regulations, interpretations, and the OSH Act can be found on www.osha.gov. Important OSHA statues and standards include:
    • Occupational Safety and Health Act of 1970
    • Section 5(a)(1), often referred to as the General Duty Clause, requires employers to “furnish to each of his employees employment and a…
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    State Programs

    • The Occupational Safety and Health Act of 1970 (OSH Act) encourages states to develop and operate their own job safety and health plans. States with plans approved and monitored by OSHA under section 18(b) of the OSH Act must adopt standards and enforce requirements that are at least as effective as federal requirements. There are currently 27 State Plan states and territories: Twenty-two of these states and territories administer plans covering both private and public (state/territory and local government) workers; the other plans, Connecticut, Illinois, New Jersey, New York, and the Virgin Islands, cover public-sector workers only.
    • Additional information on State Plans may be found at http://www.osha.gov/dcsp/osp/index.html.
    • For the most part, these OSHA-approved State Plans adopt standards that are identical to the federal OSHA standards. However, some states have adopted state-specific standards that are at least as effective as the Federal OSHA standards, including the New Jersey IAQ standard. …
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    OSHA Assistance, Services and Programs

    • OSHA offers free compliance assistance to employers and workers. Several OSHA programs and services can help employers identify and correct job hazards, as well as improve their injury and illness prevention program.
    • Establishing an Injury and Illness
    • Prevention Program
    • The key to a safe and healthful work environment is a comprehensive injury and illness prevention program.
    • Injury and illness prevention programs are systems that can substantially reduce the number and severity of workplace injuries and illnesses, while reducing costs to employers. Thousands of employers across the United States already manage safety using illness and injury prevention programs, and OSHA believes that all employers can and should do the same. Thirty-four states have requirements or voluntary guidelines for workplace injury and illness prevention programs. Most successful injury and illness prevention programs are based on a common set of key elements. …
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    OSHA Strategic Partnership Program (OSPP)

    • The OSPP provides the opportunity for OSHA to partner with employers, workers, professional or trade associations, labor organizations, and/or other interested stakeholders. OSHA Strategic Partnerships (OSP) are formalized through unique agreements designed to encourage, assist, and recognize partner efforts to eliminate serious hazards and achieve model workplace safety and health practices.
    • For more information on training, contact the
    • OSHA Directorate of Training and Education, 2020 Arlington Heights Road, Arlington Heights, IL 60005; call 1-847-297-4810; or visit www.osha.gov.
    • Susan Harwood Training Grants
    • Challenge Program
    • OSHA awards grants to nonprofit organizations to provide workers and small employers with safety and health training and education about hazard identification and prevention. Grants focus on small business, hard-to-reach workers and high-hazard industries.
    • OSHA Challenge provides interested employers and workers the opportunity to gain assistance in…
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    NIOSH Health Hazard Evaluation Program

    • OSHA’s website also has a variety of eTools. These include utilities such as expert advisors, electronic compliance assistance, videos and other information for employers and workers. To learn more about OSHA’s safety and health tools online, visit www.osha.gov.
    • Getting Help with Health Hazards
    • The National Institute for Occupational Safety and Health (NIOSH) is a federal agency that conducts scientific and medical research on workers’ safety and health. At no cost to employers or workers, NIOSH can help identify health hazards and recommend ways to reduce or eliminate those hazards in the workplace through its Health Hazard Evaluation (HHE) Program.
    • Workers, union representatives and employers can request a NIOSH HHE. An HHE is often requested when there is a higher than expected rate of a disease or injury in a group of workers. These situations may be the result of an unknown cause, a new hazard, or a mixture of sources. …
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    OSHA Regional Offices

    • Region I
    • Boston Regional Office
    • (CT*, ME, MA, NH, RI, VT*)
    • JFK Federal Building, Room E340
    • Boston, MA 02203
    • (617) 565-9860 (617) 565-9827 FAX
    • Region II
    • New York Regional Office
    • (NJ*, NY*, PR*, VI*)
    • 201 Varick Street, Room 670
    • New York, NY 10014
    • (212) 337-2378 (212) 337-2371 FAX
    • Region III
    • Philadelphia Regional Office
    • (DE, DC, MD*, PA, VA*, WV)
    • The Curtis Center
    • 170 S. Independence Mall West
    • Suite 740 West
    • Philadelphia, PA 19106-3309
    • (215) 861-4900 (215) 861-4904 FAX
    • Region IV
    • Atlanta Regional Office
    • (AL, FL, GA, KY*, MS, NC*, SC*, TN*)
    • 61 Forsyth Street, SW, Room 6T50
    • Atlanta, GA 30303
    • (678) 237-0400 (678) 237-0447 FAX
    • Region V
    • Chicago Regional Office
    • (IL*, IN*, MI*, MN*, OH, WI)
    • 230 South Dearborn Street
    • Room 3244
    • Chicago, IL 60604
    • (312) 353-2220 (312) 353-7774 FAX
    • Region VI
    • Dallas Regional Office
    • (AR, LA, NM*, OK, TX)
    • 525 Griffin Street, Room 602
    • Dallas, TX 75202
    • (972) 850-4145 (972) 850-4149 FAX
    • (972) 850-4150 FSO FAX
    • Region VII
    • Kansas City Regional Office
    • (IA*, KS, MO, NE)
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    How to Contact OSHA

    • For questions or to get information or advice, to report an emergency, report a fatality or catastrophe, order publications, sign up for OSHA’s e-newsletter
    • QuickTakes, or to file a confidential complaint, contact your nearest OSHA office, visit www.osha.gov or call OSHA at 1-800-321-OSHA (6742), TTY 1-877-889-
    • 5627.
    • For assistance, contact us. We are OSHA. We can help.
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    Appendix A: Common Indoor Air Contaminants

    • Carbon dioxide (CO 2 )
    • The purpose of this section is to provide additional information about several common indoor air contaminants.
    • Carbon monoxide (CO)
    • CO is a colorless, odorless gas produced by the incomplete burning of material containing carbon. CO poisoning 2 can cause brain damage and death. Common sources of CO are leaking vented combustion appliances, automobile exhaust, parking garages, etc. When not properly ventilated, emitted CO can build up. Employees exposed to low levels of CO may feel sick with headache and nausea, and will feel better when exposed to fresh air outside. However, their symptoms will recur shortly after returning to their workplace if CO is not eliminated.
    • CO Poisoning Symptoms
    • Poisoning due to low levels of CO can be confused with influenza symptoms, food poisoning, or other illnesses, and can be a long-term health risk if left unattended. …
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    Steps to Reduce Exposure

    • Integrated Pest Management Principles should always be implemented. Pesticide products should be used according to application and ventilation instructions provided by the manufacturer. In addition:
    • Mix or dilute pesticides outdoors;
    • Increase ventilation when using pesticides;
    • Use non-chemical methods of pest control when possible;
    • Do not store unneeded pesticides;
    • Dispose of unwanted containers safely; and
    • Keep indoor spaces clean, dry, and well ventilated to avoid pest problems.
    • Radon
    • Radon is a colorless, odorless, and tasteless radioactive gas (6, 13, 17, 39, 40). It comes from the natural decay of uranium and some other radionuclides that are present in soil. Radon is responsible for most of the public’s exposure to ionizing radiation (39, 40). It is often the single largest contributor to an individual's background radiation dose, and levels can vary widely from location to location. Radon gas can accumulate in buildings, especially in confined areas such as attics and basements. …
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    • Well-designed, -constructed and –maintained building envelopes are critical to the prevention and control of excess moisture and microbial growth by avoiding thermal bridges and preventing intrusion by liquid or vapor-phase water. Management of moisture requires proper control of temperatures and ventilation to avoid high humidity, condensation on surfaces, and excess moisture in materials. Ventilation should be distributed effectively in spaces, and stagnant air zones should be avoided (5, 8).
    • ASHRAE recommends relative humidity levels between 30 and 60 percent for optimum comfort (25). Higher humidity may result in microbial growth. A consistently implemented good-housekeeping plan is essential to eliminate or reduce the microbial growth in the building.
    • Legionella
    • Legionellosis or Legionnaires’ Disease is caused by a waterborne bacterium, Legionella, which grows best in slow-moving, or still warm water (42-44). The primary route of exposure is aerosolization, most commonly from domestic hot-water systems (e.g…
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    Appendix B: Steps to Improve Indoor Air Quality 3

    • What employers can do
    • Maintain a good working relationship with building management on indoor environmental issues.
    • Place office furniture and equipment in locations based on the adequate air circulation, temperature control, and pollutant removal functions of the HVAC system.
    • Coordinate with building management when responsibility for design, operation, and maintenance of the ventilation system is shared. Avoid procedures and products that can cause IAQ problems.
    • Integrate IAQ concerns into purchasing decisions.
    • Work with the building manager to ensure use of only necessary and appropriate pest-control practices; use nonchemical methods when possible.
    • Work with building management and the contractor before starting to remodel or renovate to identify ways of minimizing building-occupant exposure, and to ensure that the air-distribution system is not disrupted.
    • Encourage building management to develop a preventive IAQ management program following guidance issued by the…
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    Appendix C: HVAC System Maintenance Checklist 4

    • Duct and Plenum equipment
    • The following checklist can be used to investigate the HVAC system to make sure it is operating properly (e.g., the right mix of fresh air, proper distribution, and filtration systems are working, etc.) and clean.
    • Routine inspection of ducts, debris, and microbial growth (e.g., semi-annually).
    • Provisions of cleanout (e.g., within four feet downstream of duct expansions, supply air openings, or where particulate deposition may occur).
    • Ductwork attached, not dented.
    • Insulation intact, not wet, and no microbial growth.
    • Ductwork properly balanced.
    • Cooling Towers
    • Written maintenance and inspection program.
    • Operated in accordance with manufacturer specifications.
    • Inspected regularly (monthly, or as required).
    • Treatment of waste to control microorganisms, as required.
    • Recordkeeping of biocide use – brand, volume, and results.
    • Training of workers for hazards involved.
    • Humidifiers
    • Inspected weekly during operation.
    • Cleaned and disinfected as required.
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    Appendix D: Investigating IAQ Problems and Complaints

    • Identifying the cause(s) of IAQ problems and complaints may be difficult if an obvious source is not evident. Investigating unclear IAQ problems should take into account patterns and factors, such as occupant complaints and symptoms, location(s) in the building, time of day, seasonal differences, and relationship to activities inside or outside the building. Below are suggestions of information that may be helpful to collect.
    • Once information is gathered, it should then be analyzed for patterns and possible causes of the IAQ problem. The analysis may point to specific methods, such as those discussed on page 7 (Identification and Assessment). The next step is to fix problems identified and evaluate the results.
    • Has the fix resolved the problems or complaints?
    • If not, then further investigation will need to be pursued. Consultation with safety and health professionals or other experts should be considered at any point during an IAQ investigation.
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    Appendix E: Selected Resources

    • Hazard Recognition
    • IAQ problems can be caused by improperly operated and maintained HVAC systems, overcrowding, microbiological contamination, outside air pollutants, and off-gassing from materials in the office and mechanical equipment. Related problems also may include discomfort problems due to improper temperature and relative humidity conditions.
    • The following references aid in recognizing IAQ hazards in the workplace:
    • OSHA Technical Manual. OSHA Directive TED 01-00-015 [TED 1-0.15A] (1999, January 20). https://www.osha.gov/dts/osta/otm/otm_toc.html
    • Indoor Air Quality Investigation. Contains guidelines for IAQ investigations, recommendations on sampling instrumentation and methods, as well as guidelines for employers to prevent or alleviate IAQ problems. https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_2.html
    • Carbon Monoxide Poisoning. OSHA Fact Sheet (2002) . http://www.osha.gov/OshDoc/data_General_Facts/carbonmonoxide-factsheet.pdf
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    • Guidelines on Assessment and Remediation of Fungi in Indoor Environments. New York City Department of Health. Addresses mold contamination of building components (walls, ventilation systems, support beams, etc.) that are chronically moist or water damaged. http://www.nyc.gov/html/doh/html/epi/moldrpt1.shtml
    • Indoor Air Quality Publications. Consumer Product Safety Commission (CPSC). Contains an index of CPSC publications related to IAQ. http://www.cpsc.gov/cpscpub/pubs/iaq.html
    • Evaluation and Control
    • Methods used in an IAQ investigation may include: identification of pollutant sources; evaluation of HVAC system performance; observation of production processes and work practices; measurement of contamination levels and employee exposure; medical testing or physical examinations; employee interviews; and review of records of medical tests, job histories, and injuries and illnesses.
    • The following resources provide information about evaluating and controlling IAQ in the workplace.
    • Evaluation
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    • U.S. Green Building Council LEED for Existing Buildings. Leadership in Environmental and
    • Energy Design for Existing Buildings. http://www.usgbc.org/DisplayPage.aspx?CMSPageID=221#v2008
    • Control
    • A Brief Guide to Mold in the Workplace. OSHA Safety and Health Information Bulletin. October 10, 2003. https://www.osha.gov/dts/shib/shib101003.html
    • Ventilation. OSHA Safety and Health Topics Page. https://www.osha.gov/SLTC/ventilation/index.html
    • Building Air Quality: A Guide for Building Owners and Facility Managers. U.S. Department of Health and Human Services, National Institute for Occupational Safety and Health (NIOSH) Publication No. 91-114. Also, referenced as Environmental Protection Agency (EPA) Publication No. 400/1-91/003. December 1991. http://www.cdc.gov/niosh/baqtoc.html
    • Building Air Quality: Action Plan. Publication No. 98-123. Also, referenced as EPA Publication No. 402-K-98-001. June 1998. Provides an 8-step building air-quality action plan for building owners and managers to be used with NIOSH Publication No. …
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    Appendix F: OSHA- Sponsored Environmental Tobacco Smoke Workshops

    • Workshop I
    • Workshop Summary: Assessing Exposure to Environmental Tobacco Smoke in the Workplace. Jonathan M. Samet. Environmental Health Perspectives Supplements, vol. 107, no. S2, May 1999.
    • Environmental tobacco smoke (ETS) is a term now widely used to refer to the mixture of sidestream smoke and exhaled mainstream smoke that pollutes air in locations where tobacco smoking is taking place. A multidisciplinary workshop was convened to address key issues related to ETS exposure in the workplace in order to prepare the groundwork for a risk assessment of the hazard ETS poses to workers. Workshop participants concluded that substantial evidence was now available on worker exposure to ETS using both direct and indirect approaches to exposure assessment, and that these data could be used to project distribution of exposures to ETS in the nation's workplaces. …
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    References

    • U.S. EPA. An Office Building Occupant's Guide to Indoor Air Quality. http://www.epa.gov/iaq/pubs/occupgd.html
    • U.S. EPA. Indoor Air Quality. The Inside Story: A Guide to Indoor Air Quality. http://www.epa.gov/iaq/pubs/insidest.html
    • CDC. Healthy Housing Reference Manual. Chapter 5: Indoor Air Pollutants and Toxic Materials. http://www.cdc.gov/nceh/publications/books/housing/cha05.html
    • NIOSH Recommendations for the Cleaning and Remediation of Flood-Contaminated HVAC Systems: A Guide for Building Owners and Managers. http://www.cdc.gov/niosh/topics/emres/Cleaning-Flood-HVAC.html
    • American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) (2010). ASHRAE Standard 62.1. Ventilation for Acceptable Indoor Air Quality. Atlanta, GA.
    • Fisk, W.J. (2000). Health and Productivity Gains from Better Indoor Air Environments and Their Relationship with Building Energy Efficiency. Annual Review of Energy and the Environment, 25: 537-566.
    • …
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    • 24. U.S. EPA. Indoor Air Quality. Tools for Schools Action Kit IAQ Coordinator’s Guide: A Guide to Implementing an IAQ Program. http://www.epa.gov/iaq/schools/tools4s2.html
    • 25. ASHRAE Standard 55 (2010). Thermal Environmental Conditions for Human Occupancy.
    • 26. ASTM Standard D-6245-98. Using Indoor Carbon Dioxide Concentrations to Evaluate Indoor Air Quality and Ventilation.
    • 27. U.S. Consumer Product Safety Commission. Tips for Purchasing and Installing New Carpet. CPSC Document #454. http://www.cpsc.gov/cpscpub/pubs/454.html
    • 28. Carpet and Rug Institute (1999). Carpet and Indoor Air Quality Technical Bulletin. http://www.carpet-rug.org/technical_bulletins/9902_Carpet_and_IAQ.pdf
    • 29. NIOSH. Building Air Quality: Action Plan. http://www.cdc.gov/niosh/baqact4.html
    • 30. U.S. Consumer Product Safety Commission. The Senseless Killer. 1993 GAO Publication No. 1993-0-356-764.
    • 31. Mott, J. A., Wolfe, M. I., Alverson, C. J., Macdonald, S. C., Baily, C. R., Ball, L. B., et al. (2002). …
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